The Office of Personnel Management (OPM), in collaboration with the Defense Counterintelligence and Security Agency (DCSA), issued guidance for all federal agencies regarding personnel vetting and fingerprinting for new hires, in order to keep personnel security decisions despite facility closures. Many agencies have shut down badge and fingerprint enrollment stations in response to the coronavirus, hindering new hire background investigation applicants from getting fingerprints submitted. A favorable fingerprint check has been a requirement for an interim security clearance determination. The inability of a candidate to find a fingerprint location may essentially place their background investigation on hold. Until facilities are available, OPM has issued guidance to ensure candidates may continue to get to work or be onboarded.
Here is a brief summary of the memorandum from OPM:
- Agencies that have the ability to submit fingerprints electronically, process and submit e-QIPs, and issue badges will continue to do so.
- Agencies that do not have the ability to submit fingerprints electronically can continue to process new hires using agency guidance and use risk based procedures methods such as local records checks, remote identity document verification, and other methods. However, in-person I-9 documents must be completed when agencies are able to. DCSA is implementing procedures to allow for the deferral of the fingerprint submission requirement – a critical component, which will open up the capability of issuing an interim security clearance even as adjudicative decisions are delayed.
- DCSA will process background investigation submissions without fingerprint submissions, but agencies must submit them once they are able to. Investigations closed before fingerprints are submitted and FBI criminal history checks are completed cannot be adjudicated until done.
- Agencies will not be held to adjudicative reporting timelines until processes have returned to normal.
What does all of this mean? Aspects of the personnel vetting process are moving forward, and agencies may onboard personnel even without an electronic fingerprint submission, using other verification methods. But final adjudicative decisions cannot be made until an individual or agency is able to complete all aspects of the process – including electronic fingerprint submissions.
Per regulatory guidance Common Access Cards or Personal Identity Verification badges cannot be issued without a favorable criminal history check and in-person enrollment. Agencies do have the latitude to issue alternative credentials until such a time as all requirements have been met.